Fine Gael's Senator Paschal Donohue also supports East Wall Campaign
|Colette||27/08/2010||This is the submission that was made by Councillor Ray McAdam and [Paschal Donohue] to An Bord Pleanala regarding this huge project and the impact in East Wall, North Wall and the inner city area.|
Re Proposal to construct, operate, improve and maintain DART Underground railway line between Inchicore and East Wall, Dublin. Case Reference : PL29S.NA0005
Please find attached submission from Senator Paschal Donohoe and Councillor Ray McAdam to the Dart Underground Project and the specific impact of this project on the districts of East Wall and North Wall.
In introducing this we wish to emphasise the following points:-
- The current Railway Order does not recognise the residential nature of these communities. This residential dimension is explicitly recognised in the existing (and proposed) Dublin City Development Plan.
- This lack of recognition is demonstrated by the inexplicable decision to launch both tunnel boring machines (TBMs) from the East Wall area.
- This imposes an unacceptable level of burden on both of these districts. It is essential that the decision in relation to the launch of the TBMs be reversed and the level of burden be reduced through more precautionary measures and enhanced mitigation plans.
- We also want to emphasise our support for the Protect East Wall group, call for an Oral Hearing on this project and request the participation of this Group in the Oral Hearing.
- We also request our own participation in the Oral Hearing process.
This submission recognises the gain that the Dart Underground project will present to the city of Dublin. We contend that the burden of construction must be shared more equally across the entire city.
1. The need for an Oral Hearing into this project.
As this application for a Railway Order is being considered under the terms of the 2006 Strategic Infrastructure Act, the communities we represent have only had six weeks to consider the details of the documents lodged. An Oral Hearing is therefore necessary. The timeframe from when the documents were lodged to them becoming available and subsequent deadline for receipt of submissions is insufficient for detailed consideration of all the various issues of concern to the local communities. It is only through the holding of an Oral Hearing these matters and other potential difficulties will be resolved.
This is of particular importance when one considers that since the lodging of the draft Railway Order, contact numbers advertised by Irish Rail have not been manned and messages left by residents have remained unanswered. It is precisely for this reason that an Oral Hearing be held to provide a forum within which residential concerns are heard and actioned for the construction and operation phases.
Dart Underground is one of the largest infrastructural projects ever undertaken in the history of this State. Given the size of the project and the likely impact upon the communities in which the underground Dart will operate through, we would have expected a meaningful consultation between Irish Rail and all these communities. Unfortunately, the consultation undertaken by Irish Rail particularly with the community of East Wall bears little resemblance to that outlined in the Draft Railway Order. Therefore, we support the Protect East Wall group in their request for an Oral Hearing prior to any approval for a Railway Order.
We would also contend that it is necessary that East Wall and North Wall be considered as a single module during the Oral Hearing process. As these communities have been repeatedly excluded at “a stakeholder workshop”, consultation with “parties along the route” and parties “relevant to the preliminary EIS”, it is essential that the justified concerns of the residents and communities of East Wall and North Wall are adequately addressed.
2. Dublin City Development Plan recognises East Wall as a residential area – Dart Underground must do same.
This application fundamentally fails to recognise that East Wall is a residential area. The Environmental Impact Statement refers to this district as ‘industrial’. This is completely incorrect. Due to this mistake an un-acceptable amount of impacts are proposed for the East Wall district. This area consists of approximately 2,300 households with approximately 4,500 residents. The residential nature of this area is recognised in existing planning policy.
Firstly, this area is subject to an Area Action Plan. This strategy was initiated by Dublin City Council and the Docklands Development Authority in 2004 in recognition of the existing residential community and anticipated growth. This plan emphasises that:-
“The regeneration of the Docklands area, under the direction of the Authority and the City Council, now places the established residential community of East Wall in a rapidly changing economic and urban environment. From being an isolated dockland community, suffering from the decline in Port-related employment, East Wall is now at the heart of one of the fastest growing areas of Dublin city.”
Secondly, the existing and proposed Dublin City Development Plans zone the majority of land as Z1. This zoning status is to ‘To protect, provide and improve residential amenities’. This affirms the overwhelming residential nature of the East Wall district.
Due to this it is not acceptable that the current burden of impacts, as proposed by this Railway Order, be granted permission. City Development Policy recognises East Wall as a residential area. This submission asks that An Bord Pleanala also do so in their decision on the Dart Underground.
3. Re-allocate use of TBMs across the full city.
A fundamental request of this submission is to ensure that TBMs are allocated across the entire city as opposed to just the East and North Wall district. There is no justification for the allocation of all of this heavy construction work to one site. It will concentrate the burden of impacts to an unacceptable level in this area despite the fact that this district receives no particular gain from the project.
No justification for this decision is to be found in planning policy, the EIS or any statement from Iarnrod Eireann. We strongly request that it be reversed.
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[see full submission on: http://www.paschaldonohoe.ie/?p=3488]